EUDR 2023/1115 · DUE DILIGENCE · DEFORESTATION-FREE

EUDR Regulation: Deforestation Due Diligence for Industrial Companies.

The EUDR Regulation (EU 2023/1115) requires operators placing soy, palm oil, timber, cocoa, coffee, rubber and cattle — and their derived products — on the EU market to conduct due diligence to ensure they are deforestation-free and produced legally. IgeraIndustria answers every EUDR compliance question: covered commodities, geo-location requirements, due diligence statements, country benchmarking and risk mitigation. Your supply chain team finds the answer in seconds.

EUDR 2023/1115 pre-indexed Due diligence statement guidance <3s response

EUDR: geo-location, legality verification and due diligence statements for 7 commodities

Deforestation-free supply chain compliance is now a legal obligation for any company placing EUDR-covered commodities or derived products on the EU market. Yet many companies do not know whether their products fall under EUDR scope, how to obtain geo-location coordinates from suppliers in high-risk countries, or what risk mitigation measures satisfy the regulation.

7

commodities covered: cattle, cocoa, coffee, palm oil, soy, wood and rubber — plus all derived products listed in EUDR Annex I (leather, chocolate, paper, furniture, tyres).

Dec 2024

EUDR entered into force for large operators in December 2024 (delayed from June 2023 original date). SMEs have until June 2025. Micro-enterprises are largely exempt.

4% turnover

maximum fine for placing non-compliant products on the EU market — plus confiscation of products and revenues, and exclusion from public procurement.

Supply chain teams spend months mapping which products fall under EUDR scope, designing supplier data collection processes to obtain geo-location coordinates, and determining what risk level their sourcing countries carry under the Commission’s benchmarking system. IgeraIndustria answers those questions in seconds, citing the exact EUDR article and annex, so the supply chain team can focus on supplier engagement and due diligence statement submission.

Instant EUDR compliance query by requirement

IgeraIndustria locates the exact EUDR requirement that applies to each question and responds with the applicable due diligence obligation, country risk classification, and documented evidence requirement.

Scope determination — is your product covered?

EUDR Annex I lists the HS codes of all derived products covered. IgeraIndustria identifies whether your product falls under EUDR scope based on commodity content and HS code, and whether any exemptions apply (e.g., recycled or certified products meeting specific conditions).

Geo-location data requirements

EUDR requires geo-location coordinates (polygons for plots over 4 ha, single coordinate point for smaller plots) of all land where the commodity was produced. IgeraIndustria explains what precision is required, what coordinate format is accepted in the EU information system, and how to handle multi-origin batches.

Country benchmarking and risk classification

The Commission publishes a benchmarking system classifying countries as low, standard or high deforestation risk. IgeraIndustria explains what the risk classification of your sourcing country means for your due diligence obligations and what simplified or enhanced procedures apply.

Due Diligence Statement submission

Before placing EUDR-covered products on the EU market, operators must submit a Due Diligence Statement (DDS) in the EU information system. IgeraIndustria explains what data fields the DDS requires, when it must be submitted, and what reference number must appear on customs documentation.

Trader obligations vs operator obligations

EUDR distinguishes operators (who first place products on the EU market or export from it) from traders (who supply within the supply chain). IgeraIndustria identifies whether your company is an operator or trader and what simplified due diligence options are available for traders.

Risk mitigation measures

When risk assessment identifies non-negligible risk, EUDR requires risk mitigation before placing the product on the market: additional supplier information, independent audits, third-party certifications. IgeraIndustria identifies which mitigation measures are accepted and how to document them in the DDS.

Complete EUDR compliance support for industrial operators

From commodity scope assessment to geo-location data collection, due diligence statement submission and competent authority inspections, IgeraIndustria supports the supply chain and compliance team at every stage of EUDR compliance.

Commodity and HS code scope mapping

EUDR scope depends on whether your product contains relevant commodities and whether it is listed in Annex I by HS code. IgeraIndustria maps your product portfolio against EUDR Annex I HS codes, identifies products in scope, and clarifies when recycled or certified content reduces due diligence obligations.

Supplier data collection design

Obtaining geo-location coordinates from agricultural suppliers in Brazil, Indonesia or Ivory Coast requires supplier engagement programs. IgeraIndustria explains what data must be requested from each supplier tier, what data formats are accepted, and how to handle suppliers who cannot provide coordinate data.

Country risk assessment framework

Commission country benchmarking assigns low, standard or high risk to each country. IgeraIndustria explains what evidence is needed for each risk level: low-risk countries allow simplified due diligence with basic information, while high-risk countries require enhanced due diligence with third-party verification.

Due Diligence Statement preparation

The DDS must be submitted in the EU TRACES system before customs clearance for imported products. IgeraIndustria explains what information each DDS field requires, how to link the DDS reference to customs documentation (CN22/CN23, EAD), and what records must be kept for 5 years after submission.

Annual due diligence system report

Large operators must publish an annual report describing their due diligence system, the commodities and products covered, the countries and regions of supply, and the risk mitigation measures applied. IgeraIndustria explains the mandatory content of the annual report and where it must be published.

Competent authority inspections

National competent authorities (in Spain: MITECO) will inspect operators and traders annually. A minimum of 9% of operators must be inspected. IgeraIndustria explains what documentation inspectors will request, what the inspection procedure involves, and how to respond to requests for additional information.

The 3-step EUDR due diligence process

These three steps define the mandatory due diligence process that operators must complete before placing EUDR-covered commodities and derived products on the EU market or exporting them from it.

Step 1 — Information collection

Operators must collect: (a) description, quantity and HS code of the product; (b) country and sub-national region of production; (c) geo-location coordinates of all plots of land where the commodity was produced (polygon for plots >4 ha, GPS point for smaller plots); (d) date or time range of production; (e) name and contact details of the supplier; (f) name and contact details of the trader to whom the product is supplied; (g) adequately conclusive and verifiable information that the commodity is legal and deforestation-free.

Step 2 — Risk assessment

Operators must assess whether there is a risk that products do not comply with EUDR requirements. The assessment must consider: (a) the Commission’s country/region benchmarking (low/standard/high risk); (b) presence of forests in the production area at the cut-off date (31 December 2020); (c) prevalence of deforestation or forest degradation in the country; (d) supply chain complexity and length; (e) third-party or government verification schemes; (f) concerns raised by competent authorities.

Step 3 — Risk mitigation

If the risk assessment identifies non-negligible risk, operators must adopt risk mitigation measures proportionate to the level of risk before placing the product on the market: (a) require additional information, documents and evidence from suppliers; (b) carry out independent surveys or audits of suppliers; (c) require suppliers to obtain third-party certifications aligned with the EUDR objectives; (d) support suppliers in achieving compliance. Only after risk is negligible (or in the case of low-risk countries, simplified due diligence) may the Due Diligence Statement be submitted.

Due Diligence Statement submission

After completing the three steps and concluding that risk is negligible, the operator must submit a Due Diligence Statement in the EU information system before placing the product on the market or exporting it. The DDS reference number must be included in customs declarations. The DDS and all supporting documentation must be kept for at least 5 years. Competent authorities can access DDS data for inspection purposes.

How IgeraIndustria works for EUDR 2023/1115

Five steps from loading your supply chain documentation to receiving an answer with the exact EUDR article, applicable due diligence obligation, and risk mitigation requirement for your commodity.

01

Index your supply chain compliance documentation

Upload your supplier contracts, existing sustainability certifications (RSPO, FSC, Rainforest Alliance), internal supply chain mapping data, and country risk assessments. IgeraIndustria processes them together with the full EUDR 2023/1115 text and Commission guidance documents in under 24 hours.

02

Connect the assistant to your supply chain and compliance team

Embed it in your procurement portal, Teams, Slack or as a standalone tool for the supply chain and sustainability team. One line of code. Compatible with any ERP or supply chain management system.

03

Ask in plain language

«Does our cocoa-butter ingredient for pharmaceutical use fall under EUDR scope?», «Our Brazilian soy supplier cannot provide polygon coordinates — what alternatives does EUDR allow?», «Malaysia is classified as standard risk — what due diligence do we need for palm oil?»

04

IgeraIndustria searches across 2 knowledge layers

First in your internal supply chain documentation (supplier data, certifications, risk assessments), then in the indexed EUDR 2023/1115 text, Commission guidance notes, and country benchmarking system.

05

Answer with regulation reference and applicable obligation

The response cites the applicable EUDR article or annex, states the due diligence obligation for your specific commodity and sourcing country risk level, explains what geo-location data must be collected, and identifies what risk mitigation measures apply.

IgeraIndustria in action — EUDR palm oil due diligence

EUDR due diligence query for palm oil ingredients sourced from Malaysia resolved in under 3 seconds with the applicable risk level and required evidence.

IgeraIndustria — Widget EUDR 2023/1115

Supply Chain Compliance Manager

We import palm oil derivatives from Malaysia for use in our industrial lubricants. Malaysia is classified as standard risk under EUDR. What due diligence do we need to complete?

IgeraIndustria

EUDR — Palm oil from Malaysia (Standard Risk)

Full due diligence required (standard risk = no simplification):

  • • Step 1: Collect geo-location coordinates (polygon/GPS) of all Malaysian plantations producing your palm oil lots; obtain supplier legality evidence under Malaysian law
  • • Step 2: Risk assess each plantation using satellite data or third-party verification — confirm no deforestation after 31 Dec 2020
  • • Step 3: If any plantation risk non-negligible — require RSPO certification or independent audit before use

Accepted certifications that support risk mitigation:

  • • RSPO Mass Balance or Segregated certification — covers deforestation-free claim with supporting evidence
  • • Submit Due Diligence Statement in TRACES before customs clearance

⚠️ Palm oil derivatives in lubricants (HS 1511, 3403) are in EUDR Annex I scope — confirm HS code with your customs broker before importing

✓ EUDR 2023/1115 Art. 8-11 + Annex I · Confidence: 97.8%

340

suppliers geo-located

6 wks

to first Due Diligence Statement

0

shipments delayed at customs

We use soy derivatives, palm oil and rubber in our industrial products and had 340 upstream suppliers to geo-locate under EUDR. IgeraIndustria helped our supply chain team understand exactly what data to request from each supplier tier, how to structure our risk assessment for each sourcing country, and what the Due Diligence Statement required. We submitted our first DDS six weeks after starting and have had zero customs delays since EUDR entered into force.

Head of Supply Chain Compliance

Industrial chemicals manufacturer — 340 suppliers — Tarragona

*Representative testimonial based on results from real customers

Frequently asked questions — EUDR 2023/1115

Which commodities and derived products are covered by EUDR?

EUDR covers 7 key commodities: cattle, cocoa, coffee, palm oil, soy, wood and rubber. And their derived products listed in Annex I: leather, chocolate and cocoa preparations, coffee products, palm oil and its fractions, soya bean oil and meal, wood products (including paper, cardboard, printed products and furniture), natural rubber and rubber products (tyres, gloves). EUDR requires that these products are deforestation-free (produced on land not deforested after 31 December 2020) and legal in the country of production.

What does EUDR due diligence require in practice?

EUDR due diligence has three steps: (1) Collect information — obtain geo-location coordinates of all plots of land where commodities were produced, along with country of production, supplier details and quantity; (2) Risk assessment — evaluate the risk of non-compliance using country/region benchmarking published by the Commission, supply chain complexity, and presence of forests in the production area; (3) Risk mitigation — if risk is non-negligible, take measures to address it (additional audits, third-party verification, require supplier certifications) before placing the product on the market. A Due Diligence Statement must be submitted in the EU information system.

What are the penalties for EUDR non-compliance and who is enforcement authority?

EUDR penalties must be effective, proportionate and dissuasive. The maximum fine must be at least 4% of the operator’s annual EU turnover, with higher fines for repeat infringements. Other sanctions include: confiscation of the non-compliant products, confiscation of revenues derived from the transaction, temporary exclusion from public procurement, and temporary prohibition from placing products on the EU market. In Spain, the competent authority will be designated by the Ministry for Ecological Transition (MITECO). Large operators must submit annual reports on their due diligence systems.

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